charge any interest, the rate of interest
charged on loan should be LIBOR plus by taking the following cases:
1. Geodesic ... benchmark its returns with the domestic
interest rate rather than Libor. The ideal interest rate on
outbound intra-group loans would be that interest rate
erred in benchmarking the transaction at SBI Prime Lending Rate
and not LIBOR since the denomination of the loan in question was US
Dollars ... provisions of the DTAA .
6. On ground 4A, he submitted that LIBOR has to be applied in preference to SBI Prime
lending rate
charged as per the interest rate in
foreign currency i.e. LIBOR.
7. The learned DRP did not agree with the contention of the assessee ... money has been advanced in
US Dollar it has to be LIBOR. In respect of advances in Euro the interest
rate
charged as per
the interest rate in foreign currency i.e. LIBOR.
7. The learned DRP did not agree with the contention of the
assessee ... money has been advanced in US Dollar it has to
be LIBOR. In respect of advances in Euro the interest rate
given out of denominated
funds. He has also rejected the applicability of LIBOR rate for
benchmarking and accordingly, he calculated the interest rate made ... currency, then arms length interest rate has to be
considered at EURIBOR/LIBOR only and accepted the assessee's
benchmarking of the interest rate
